Honey, I Paused the FCPA!
Jared Russell
2025 Q1 Review on FCPA, Compliance, and Investigation
If I had to sum up the start of 2025 for the FCPA, compliance, and investigations arena, I’d say it’s been less “Foreign Corrupt Practices Act” and more “Frantic Compliance, Please Adapt!” Like a plot twist straight out of a retro family comedy, Q1 opened with shockwaves: seismic policy shifts, global shakeups, and the rise of AI-driven enforcement. While the initial chaos has passed, the aftershocks are still being felt as fast-moving changes have become the new norm. Buckle up for a recap of Q1’s biggest moves, insights from the field, and a timeline of key moments to help you keep pace. ⚠️ Spoiler alert: The watchdog isn’t sleeping – it’s just relocated overseas.
🔑 Key Takeaways That Stole the Spotlight
Before diving in, here are some bite-sized gems from recent events I attended:
[Event] FCPA Houston Conference: Collaboration is the new compliance superpower. Experts at this event hosted by American Conference Institute emphasized cross-functional teamwork as the secret sauce for tackling modern bribery risks and staying ahead of evolving enforcements.
[Panel] SEC Enforcement: What to Expect Under New Administration: Defense counsel warned that fewer resources could slow investigations, making cooperation more complex and more critical. Even if enforcement slows, the mission doesn’t disappear! Presented by an expert panel from The Texas Lawbook, Association of Corporate Counsel, U.S. Securities and Exchange Commission, Holland & Knight LLP, and Vinson & Elkins.
[Event] Mexico Anti-Corruption Summit: Enforcement south of the border is heating up. Multinational companies need laser-focused compliance programs that blend local expertise with global standards to navigate Mexico’s evolving anti-corruption landscape. Shoutout to my colleague, Maria Fernanda Gallo, who attended this event from American Conference Institute and provided great insight.
[Webinar] Corruption and compliance in flux: The impact of the Executive Order pausing enforcement of the FCPA: The EO pausing FCPA enforcement doesn't equate to a free pass. DLA Piper's white-collar experts, all former government enforcers, emphasized that multinational corporations must remain vigilant, reinforcing the temporary nature of the current pause.
[Webinar] Streamlining Internal and Compliance Investigations with Analytics & AI: Technology is a true game-changer. AI and analytics can slash investigation timelines and pinpoint risks faster than you can say “whistleblower hotline.” If you haven’t caught TransPerfect Legal’s March webinar (replay here), you’re missing out!
🗓️ 2025 Q1 Timeline: The Big Moments You Need to Know
Here’s a rundown of the quarter’s defining beats in the FCPA and compliance space:
📍 January
2024 wrapped with $1.28B in FCPA fines. Early signals from the DOJ and SEC suggest that individual accountability remains a top priority.
📍 February 5
AG Pam Bondi memo redirects DOJ focus, pivoting from traditional bribery cases to cartel and transnational crime enforcement.
📍 February 10 ⏸️ FCPA Pause Button ⏸️
Trump’s Executive Order freezes new FCPA investigations for 180 days. DOJ is asked to assess whether enforcement harms U.S. competitiveness.
📍 March 6
Compliance advisors urge companies not to hit cruise control. Despite the pause, Stanford FCPA Clearinghouse data shows foreign companies often face larger penalties, undercutting claims that U.S. firms are unfairly targeted.
📍 March 12
The SEC informally joins the DOJ's pause. Enforcement slows, with more openness to declinations for self-reporting, cooperative companies.
📍 March 20
Europe steps in as the U.S. steps back. The UK, France, and Switzerland launch the International Anti-Corruption Prosecutorial Taskforce.
📍 March 20 (cont.)
DOJ ends Glencore’s FCPA monitorship 15 months early, hinting at a trend toward fewer or shorter monitorships going forward.
📍 March 25
DAG Todd Blanche proposes DOJ restructuring. Fewer FCPA staff and realigned Fraud Section priorities signal further shifts in enforcement strategy.
🔮 August 9
Predicting the Future? This would be the earliest date new FCPA investigations could resume, assuming no extensions or changes are made to the executive order. Rather than hold your breath, leaders should continue to fortify compliance programs to stay ahead of risk.
🎬 What’s Next? Your Move, Compliance Champs
⚠️ Don’t mistake the pause for the end credits. There’s still time left in this movie, though it’s unclear whether we’re watching a low-budget horror film, a rebooted ‘90s comedy, or a slow-burning sequel no one really asked for. In the meantime, smart leaders are staying ready for the next plot twist.
Whether it’s leveraging AI to supercharge investigations, teaming up with cross-border taskforces, or keeping an eye on enforcement pivots, the compliance landscape is evolving fast.
My advice? Dive into these resources, connect with peers, and keep the conversation going!!
